Date: 4/6/99 12:39 PM Re: File No. S7-9-99 Dear Sir or Madam, I believe you are incorrect in your assessment of what SSL provides in terms of non-repudiation. SSL provides a secure channel, and potentially authorization of what the connecting client's identity may be. It does not validate or provide non-repudiable transaction, a time-stamp of the transactions themselves, any digital signing of a transaction, or any form of legal verifiability. Differential has a solution which directly addresses the non-repudiation issues that you are currently seeking in your online initiatives of bringing EDGAR to the Internet and supporting HTML formats. Differential's eReceipt line of products supports: - a non-repudiable digital document which verifies the time, date, and parties involved in a transaction - a high-performance transaction confirmation server which can generate up to 120 digitally signed documents per second, and securely logs all transactions in a tamper-proof log (even by administrators) - a transaction warehouse server which pulls in digital receipts from any number of sources and provides reconciliation and reporting for receipts - and much much more We would be happy to meet with any representative from the SEC to discuss the issues with legally verifiable transactions on the internet, at your convenience. I will also be attending the Uniform Electronic Transactions Act on April 9th in Emeryville, CA. Thank you for your time, -Kent. _____________________________________________________________ Kent M. Davidson Vice President of Engineering Differential, Inc. "Closing the loop in Electronic Commerce" main (650)426-1100 fax (650)426-1101 mailto:kent@differential.com http://www.differential.com